AML・OFAC：Settlement between  OFAC and Generali Global Assistance, Inc.

By AML OFAC, AML

AML・OFAC：Settlement between  OFAC and Generali Global Assistance, Inc.

Generali Global Assistance, Inc.：

10/01/2020

The U.S. Department of the Treasury’sOffice of Foreign Assets Control (OFAC)

today announced a settlement with Generali Global Assistance, Inc. (GGA), a New York-incorporated travel assistance services company.

GGA
agreed to remit $5,864,860 to settle its potential civil liability for 2,593 apparent violations of the Cuban Assets Control Regulations.

GGA intentionally referred the Cuba-related payments to its Canadian affiliate,
thereby avoiding processing reimbursement payments directly to Cuban parties and to travelers while they were located in Cuba.

GGA then subsequently reimbursed its Canadian affiliate for those payments.
GGA formally codified this indirect payment process in its procedures manual.

OFAC determined that the case was voluntarily self-disclosed to OFAC and that the apparent violations constitute an egregious case.

U.S. Department of the Treasury

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201001_33

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